MONEY
LAUNDERING & ANTI-TERRORISM

Canada's
Proceeds of Crime (Money Laundering) and Terrorist Financing Act ("Act")
demonstrates the government's commitment to fight money laundering and contributes
to international efforts to detect, deter and prevent money laundering and
seize criminal and terrorist funds. The Hughes Trustco Group Ltd. adheres
strictly to the following guidelines and is strongly supportive of these
efforts.

The
suspicious transactions regulations require financial institutions and other
intermediaries to report financial transactions to the Financial Transactions
and Reports Analysis Centre of Canada (FINTRAC), the newly created government
agency, if there are reasonable grounds to suspect they are related to the
commission of a money laundering offence. FINTRAC collects and analyzes these
reports and discloses suspicions of money laundering to law enforcement agencies
and others as required by legislation.

Reporting
of Terrorist Financing and SWIFT Cross Border Transactions and New Requirements
for Identifying and Verifying Account Owners

A transactions related to terrorist financing

Possession of terrorist assets

Knowledge of a financial transaction involving such assets

Such
transactions are reported to FINTRAC

Reporting
certain large transactions and cross border movements

There
is a series of requirements for reporting whenever currency and/or negotiable
monetary instruments are physically moved into or out of Canada. The threshold
for reporting has been set at CAD 10,000. The designated monetary instruments
include:

Securities (e.g. stocks, bonds, debentures and treasury bills in bearer form
or in transferable order)